India ESG rulebook
Applicability finder: coverage of each ESG rule
One table of the thresholds that decide which Indian ESG rules apply to which companies, from the top 1,000 for the BRSR to CSR, RPT, CCTS, POSH and DPDP thresholds.
Use this table to check which rules apply to a company. Thresholds based on market capitalisation use the ranking at the end of the previous financial year.
Disclosure and assurance
| Rule | Who it covers | Threshold or test |
|---|---|---|
| BRSR | Listed companies | Top 1,000 by market capitalisation |
| BRSR Core assessment or assurance | Listed companies | Top 150 (FY 2023-24), top 250 (FY 2024-25), top 500 (FY 2025-26), top 1,000 (FY 2026-27) |
| BRSR Core value chain disclosures | Listed companies | Top 250, voluntary from FY 2025-26; partners making up 2% or more of purchases or sales; assessment voluntary from FY 2026-27 |
| Green debt and ESG debt rules | Issuers of listed debt securities | Any listed green, social, sustainability or sustainability-linked issue; independent reviewer required |
Governance
| Rule | Who it covers | Threshold or test |
|---|---|---|
| Independent directors | Listed companies | At least one-third of the board if the chair is non-executive; at least half if the chair is executive, or a promoter or related to one |
| Woman director | Listed companies | At least one; at least one independent woman director for the top 1,000 |
| Risk management committee; D&O insurance for independent directors | Listed companies | Top 1,000 |
| Material related-party transactions (shareholder approval) | Listed companies | 10% of consolidated turnover up to ₹20,000 crore; ₹2,000 crore plus 5% above ₹20,000 crore, up to ₹40,000 crore; ₹3,000 crore plus 2.5% above ₹40,000 crore, capped at ₹5,000 crore. Brand and royalty payments: 5% of consolidated turnover |
| CSR | Companies | Net worth ₹500 crore or more, turnover ₹1,000 crore or more, or net profit ₹5 crore or more in the previous year; spend 2% of average net profit of the three preceding years |
| CSR committee | Companies covered by CSR | Required unless the yearly CSR obligation is ₹50 lakh or less |
| CSR impact assessment | Companies covered by CSR | Average CSR obligation of ₹10 crore or more, for large projects |
| CSR through ZCZP instruments | Companies covered by CSR | Up to 10% of yearly CSR spending; project to be completed within three financial years |
Climate and environment
| Rule | Who it covers | Threshold or test |
|---|---|---|
| CCTS compliance targets | Obligated entities | About 490 entities in aluminium, cement, chlor-alkali, pulp and paper, petroleum refining, petrochemicals, textiles and secondary aluminium; 255 iron and steel entities in a revised draft (June 2026) |
| Renewable consumption obligation | Designated consumers, including distribution companies and large users | 29.91% in FY 2024-25, rising to 43.33% by FY 2029-30 |
| Plastic packaging EPR | Producers, importers and brand owners | Collection, recycling and recycled-content targets |
| End-of-life vehicle EPR | Vehicle producers | From 1 April 2025 |
| SO2 rules for thermal power | Coal power plants | Near the NCR and million-plus cities by December 2027; near critically polluted areas by December 2028 or exemption; others exempt from FGD if stack heights meet limits |
| CAFE III | Makers of passenger vehicles under 3,500 kg | From April 2027; fleet target falls to 78.9 g CO2 per km by FY 2031-32 |
| EU CBAM | EU importers of covered goods (Indian exporters indirectly) | Importers of more than 50 tonnes a year of iron and steel, aluminium, fertilisers or cement (electricity and hydrogen have no exemption) |
Social and data
| Rule | Who it covers | Threshold or test |
|---|---|---|
| POSH Internal Committee | Employers | 10 or more employees |
| Prior approval for layoffs, retrenchment and closure | Industrial establishments | 300 or more workers |
| Gig worker social security contribution | Aggregators | 1% to 2% of annual turnover, capped at 5% of payments to platform workers, once rules are notified |
| DPDP Act duties | Data fiduciaries | All; extra duties for significant data fiduciaries named by the government |
| EU CSDDD | EU and non-EU companies | EU: more than 5,000 employees and €1.5 billion turnover; non-EU: €1.5 billion EU turnover; from 26 July 2029 |
| EU CSRD (after Omnibus I) | EU companies and non-EU groups | More than 1,000 employees and €450 million turnover; non-EU groups with €450 million EU turnover and an EU subsidiary or branch above €200 million |
Finance and investment
| Rule | Who it covers | Threshold or test |
|---|---|---|
| ESG mutual fund schemes | Mutual funds | At least 80% in the stated strategy; at least 65% in companies with a full BRSR and BRSR Core assurance |
| Green deposits | Banks, small finance banks, deposit-taking NBFCs and HFCs | Optional; if raised, framework, external review, yearly verification and impact report |
| SSE registration | Non-profits | At least three years old; spent ₹50 lakh and received ₹10 lakh in the previous year; valid income tax registration |
| ZCZP issue | Registered non-profits | Minimum issue ₹50 lakh; minimum application ₹1,000; 75% minimum subscription (50% in some cases) |
| ESG rating providers | Providers of ESG ratings on Indian securities to users in India | SEBI registration as Category I or II |
Sources
- KPMG First Notes: SEBI framework on BRSR Core and value chain disclosures
- Maheshwari & Co: LODR Fifth Amendment 2025, revised RPT materiality
- ICAP: India notifies emission intensity targets under CCTS
- K&S Partners: revised Renewable Consumption Obligation guidelines, 2025
- SCC Online: SEBI master circular on the Social Stock Exchange framework (January 2026)
- DLA Piper: CSDDD amendments under Omnibus I finalised (2026)
Last reviewed: October 2026